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8 throughout its brief. What a prosecutor should have done is not relevant; whether or not the Southern District of Florida should have prohibited the Southern District of New York from prosecuting Ghislaine Maxwell, it clearly did so. Nor can the government’s appeal to context exclude Petitioner from the clear “including but not limited to” language which unmistakably signaled an intent to cover all “potential coconspirators,” not just those who were specifically named. Indeed, the broad “including but not limited to” clause shows the parties contemplated both known and unknown accomplices, and it was the government who drafted in the “final broad language,” intentionally declining to further enumerate individuals. OPR:70,166. The purpose was to assure Epstein that pleading guilty would protect all his associates from federal prosecution* — effectively “closing” the federal case completely.’ That purpose is perfectly consistent with the plain text; it is the government’s after-the-fact spin that is inconsistent, 4 The government cherry picks snippets of testimony from the OPR report, many of which are inconsistent with other statements from the same government attorneys, or which offer the perspective of those who admitted to unclear memories, or who were on vacation or otherwise disengaged at the relevant time. App.108, OPR: 36-37. There was a lengthy back-and-forth negotiating process to the inclusion of this clause, some of it recorded by the OPR report, some not. See OPR:36. None of this is relevant; the document says what it says in plain language, so the after-the-fact and self-serving statements of various participants to the process should be ignored. > The OPR is riddled with statements reflecting that the government was very concerned about the strength of its case, that it had doubts it would result in a guilty verdict, and that many of the alleged victims did not want any aspect of the case to go to trial. See, e.g., OPR:28, 29, 36, 37, 14, 147. DOJ-OGR-00000252